In the past few weeks, our world in healthcare has turned sideways. Covid-19 is changing the way we live, practice, and work.
As Nurse Practitioners, we’ve seen significant changes in the rules and regulations of how we practice. Some states have implemented Full Practice Authority, while others have relaxed some of the restrictions over our practices. Federally, we’ve been allowed to finally sign home health orders.
Many of these new rules are temporary and designed to meet current healthcare needs. And yet, I have to ask…will the “genie go back into the bottle” when the crisis is over? I think not.
Nearly all NP business owners I have spoken with or who have posted in our Facebook groups have their practices impacted by Covid-19.
While we talked about this previously, in this article, I’d like to focus on the implementation of telehealth. If you have not yet done so, you’ll want to consider adding this service to your offerings as soon as possible.
Rules and Regulations
The rules and regulations have been changing at a rapid pace. Many rules regarding the implementation, security, and accessibility for telehealth have been relaxed significantly.
For example, “During the COVID-19 national emergency, which also constitutes a nationwide public health emergency, covered health care providers subject to the HIPAA Rules may seek to communicate with patients and provide telehealth services, through remote communications technologies.
Some of these technologies and the manner in which they are used by HIPAA covered health care providers, may not fully comply with the requirements of the HIPAA Rules.” (Source HHS). For example. some rules state providers may use popular applications such as Facebook Messenger video chat, Google Hangouts video, Zoom, or Skype to provide services.
Some payers have relaxed requirements for patients to pay co-pays. However, keep in mind that those co-pays are also part of your reimbursement, and thus, your total reimbursement will be less for the same services rendered.
CMS has also issued new guidelines for virtual visits. For example, the originating site requirement has been waived and allows Medicare beneficiaries to receive audio-video medically necessary services from a qualified healthcare provider.
Medicare beneficiaries can now receive telehealth services in any health care facility, including healthcare provider offices, hospitals, nursing homes, and rural health clinics, as well as from their homes.
One question that comes up is the rule that states, “Patient must initiate the service and give consent to be treated virtually, and the consent must be documented in the medical record before initiation of the service.” The way I understand this rule is that you cannot just initiate the service with a Medicare beneficiary, but it needs to be a patient who is reaching out for services.
I encourage you to stay abreast of changes that affect your practice through your state organizations and the American Association of Nurse Practitioners (AANP) as well as CMS.
CPT codes – typically your usual E&M codes along with telehealth POS 02 and potentially a modifier (if required by the commercial payer).
In the CMS Telehealth Services MLN Booklet, they provide a variety of codes to use when billing for telehealth services.
For example, use your typical E&M code for services; with office or other outpatient visits, you would use 99201-99215.
If the rendered services are performed through an “asynchronous telecommunications system” you’ll want to add the GQ modifier.
I encourage you to download the CMS booklet for further codes and requirements.
In general, commercial payers follow Medicare guidelines for documentation and coding. However, you’ll want to check with your individual payer in terms of appropriate codes and modifiers.
Have you ever called an insurance company to check on the status of a claim, or to find out if something is covered only to hear that recording that says “Coverage is no guarantee of payment”?
Well, it applies here as well. For example, someone with a Blue Cross plan may be covered in your office for care, but their particular plan may or may not cover telehealth services. So just like with a regular, in-person visit, you’ll want to verify coverage prior to the visit.
And while you are verifying coverage, there are a few other questions you want to ask.
Questions to ask when you are verifying services:
- What codes will they pay for? (They may not give you the list of codes, so ask them specifically about the codes you are most likely to use)
- Do they require a modifier?
Many of the third-party payers have issued guidance as to which codes will be covered, what they are waiving, and any other requirements. Indeed, many of them, including CMS is paying on par with in-person visits.
Many EHRs have a telemedicine platform included or as an add on. They are not included in this list. Contact your vendor to learn more about your system.
Stand-alone platforms generally offer a variety of plans. Some are completely free and others charge per provider per month.
In addition to the price point, you’ll want to take a look at all the features and ease of use.
- Does it work with your EHR?
- Can you prescribe through the platform?
- Are you able to take payments with the platform?
- Can you screen share?
- What is the patient-user interface like? Is it easy to use?
- Is it available on mobile devices as well as desktop computers, and is it available in most operating systems?
- Is it HIPAA compliant? Yes, during this pandemic, that is waived, however, you’ll want to evaluate this for long term utilization.
At the very least be able to trial the software to see how it works for you,
Here are just a few of the options for you to evaluate.
- Doxy.me* https://doxy.me/. Doxy offers a free plan as well as other plans that offer more bells and whistles. It’s popular among clinicians. I’m told the paid plans offer better visuals.
- Google G Suite Hangouts* https://gsuite.google.com/industries/healthcare/. G-Suite comes with a variety of services and starts at $6/user/month.
- Skype for Business https://www.skype.com/en/business/. The pricing is unknown.
- Updox * https://info.updox.com/telehealth-video-chat-platform The pricing is unknown.
- Vsee* https://vsee.com/Vsee starts with a free trial and is $49/mo for its basic plan.
- Zoom. https://zoom.us/.Zoom is a fabulous platform and a favorite of mine. However, it is not, in its regular platform HIPAA compliant (though I’ve read it’s just as secure). That said, it’s permissible to use at this time.
- Zoom for Healthcare* is HIPAA compliant and starts at $200/mo. https://zoom.us/healthcare
*HIPAA Compliant Platforms
If you are using one of the non-HIPAA compliant platforms, make sure you keep up to date with the current HHS/OCR HIPAA requirements for telehealth.
CMS – MLN Booklet Telehealth Services (Updated March 2020)
Coronavirus (COVID-19): new telehealth rules and procedure codes for testing https://www.aafp.org/journals/fpm/blogs/gettingpaid/entry/coronavirus_testing_telehealth.html)
Notification of Enforcement Discretion for Telehealth Remote Communications During the COVID-19 Nationwide Public Health Emergency https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html)
Are you using telehealth in your practice? What platform are you using that has been successful for you? Please share your experiences below.